Quiet Disclosure Guilty Plea
Florida man pleads guilty to tax evasion and hiding funds around the world
In April 2020, a Florida man pleaded guilty to tax evasion and the willful failure to file FBAR’s. What makes this case particularly interesting is that the taxpayer…
Real Estate Ownership in a self-directed Investment Retirement Account; avoiding the hidden risks
Real estate ownership in a Self-Directed Investment Retirement Account (IRA) can provide certain tax benefits to taxpayers who are considering an investment in real estate. However, a retirement account considering such a strategy should be…
Bank Fraud and Criminal Tax Charges Against Michael Avenatti
Michael Avenatti’s Indictment
The temptation to use unfilled or altered tax returns as well as doctored financial statements for purposes of securing a bank loan, while not common, does occur. This practice typically occurs where an individual…
Taxing Foreign Corporations in the Digital Age
Effectively Connected Income and it's Tax Consequences
Foreign entities that deliver digital goods and services using the internet as a point of distribution may be subject to U.S. income tax. The nature and character of the goods and services…
Good News for Rental Property Owners; Qualified Business Deduction
Business Income Deduction for Taxpayer
On September 24, 2019, the IRS issued Revenue Procedure 2019-38 now permitting certain taxpayers who hold an interest or interests in rental real estate to be treated as a trade or business for purposes…
Trust Fund Recovery Penalty; Consequences of Fraudulent Conveyances
Fraudulent Conveyances in Employment Taxes
Employers who willfully fail to remit an employee’s withholding to the IRS are liable to the IRS for the “trust fund recovery penalty” (TFRP). Generally, the IRS will assess the Penalty against…
Tax Relief for Expats who Renounce U.S. Citizenship
Relief Procedures for former U.S. Citizens
The new procedures attempt to address problems faced by some U.S. citizens, whose only connection with the United States is that they were born in America. Many of these individuals have been living…
Employment Tax Consequences with Workers Misclassification
Employee versus Independent Contractor
Deciding whether to classify an individual as an employee or independent contractor is a decision which requires a careful evaluation of many factors and the assistance of a tax attorney. A…